SO 14001:2015 ISO/TC 207/SC 1 reviewed interpretations 2019 14001... · SO 14001:2015 ISO/TC 207/SC...

Version – July 2019 SC1 website related to interpretations 1 ©ISO/TC 207/SC 1

SO 14001:2015 ISO/TC 207/SC 1 reviewed interpretations 2019 Version – September 2019

Introduction To help clarify the intent of ISO 14001:2015, the ISO process allows for interpretations to be provided by each National Member Body (NMB).

The sub-committee (SC1) has a process for managing interpretations of ISO 14001:2015. It is important to note that Interpretations do not change the requirements in ISO 14001:2015 but are intended to give users a better understanding on ISO 14001:2015.

The SC1 process includes:

it is the responsibility of each National Member Body (NMB) to respond to any interpretation enquiries it receives;

NMB interpretations are submitted to SC1 on an annual basis and reviewed at the SC1 plenary;

after the review, the interpretation is made available to the public via the e-Committee and the SC1 website;

questions about the interpretation should be referred to the NMB where the interpretation originated. Please note that some NMB use the term ‘clarification of intent’ instead of the term ‘interpretation’.

Clause in ISO 14001

Question Response NSB Year reviewed by SC 1 plenary

General ISO 14001:2015 has a very different structure than

the two previous versions. Our documentation is

aligned to the clauses that existed in the previous

version. Do we have to restructure our

documentation to follow the new clause

structure?

No.

Clause A.2 states: “The clause structure and some of the

terminology of this International Standard have been changed

to improve alignment with other management systems

standards. There is, however, no requirement in this

International Standard for its clause structure or terminology

to be applied to an organization’s environmental management

system documentation.”

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General The question deals with the issue where to draw

the border line between legal requirements on

the protection of the natural environment and

those protecting occupational health and safety

issues, when it comes to certification of an

environmental management system under ISO

14001. The certification body found that our

environmental management system did not fully

comply with the requirements in ISO 14001:2015,

since the documentation of legal requirements,

linked to some of the environmental aspects, did

not include some of the pieces of legislation

covering occupational health and safety issues.

According to our company there is no link

between any of the environmental aspects and

occupational health and safety issues.

All organizations are obliged to comply with all applicable

legislation. This case deals with the legal requirements that

need to be taken into account in the environmental

management system under ISO 14001:2015. The standard says

that the organization shall ”determine and have access to the

compliance obligations related to its environmental aspects,

determine how these compliance obligations apply to the

organization and take these compliance obligations into

account when establishing, implementing, maintaining and

continually improving its environmental management system”

(Section 6.1.3). Furthermore, the organization shall ”maintain

documented information of its compliance obligations”

(Section 6.1.3).

The concept of compliance obligations is broader than legal

requirements, i e it is a generic term for "legal and other

requirements". The handling of such other requirements

follow the same procedure that applies to the legal

requirements.

According to the question, there are no environmental aspects

in this case that can be linked to legal requirements concerning

occupational health and safety issues, implying that they do

not need to be included the mentioned documented

information in accordance with the requirements of ISO 14001:

2015. However, it is necessary to pay attention to some

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regulation outside the environmental arena. For example, the

Swedish Civil Contingencies Agency, may have issued

legislation on the transport of hazardous goods that may

include rules that are applicable to both the natural and

working environment. In principle, the same procedures apply

for those organizations that still use ISO 14001: 2004.

However, organizations that have implemented an

environmental management system under ISO 14001 may find

it useful to include other than environmental issues in its

management system. If so, an organization may consider it

appropriate that its management system keeps track of both

environmental and non-environmental legal requirements of

importance. Such aspects and legal requirements shall not be

considered and consequently be excluded in the certification

of an environmental management system established under

the ISO 14001: 2015. If, on the other hand, the organization

has chosen to include non-environmental issues in the scope of

its environmental management system it also includes

corresponding legal requirements.

General

6.1.1,

6.1.3

In some places in the Standard, the organization

is directed to take certain items into account,

while in other places in the Standard, the

organization is directed to “consider” certain

items. Is there a difference?

ISO 14001 uses the word “consider” and the phrase “take

into account” with a specific intent. The word “consider”

means it is necessary to think about the topic but it can be

excluded; whereas “take into account” means it is necessary

to think about the topic but it cannot be excluded.

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As an example, in Section 6.1.1, when planning its EMS, the

organization shall consider the issues referred to in Section

4.1, “Understanding the organization’s context”. ISO 14001

requires the organization to think about these issues, but it

does not necessarily have to address these issues in its EMS.

Alternatively, in Section 6.1.3, “Compliance obligations” for

example, the requirement “take these compliance

obligations into account when establishing, implementing,

maintaining and continually improving its EMS, means the

organization must address its compliance obligations in its

EMS.

3 Are the references to other standards in the Notes

to Entry in Clause 3 (Terms and definitions)

normative?

No.

A normative reference is a reference to another document that

is indispensable for the application of the standard. If a

document is normatively referenced, an organization must

conform to it in order to conform with the standard. As Clause

2 states, there are no normative references in ISO 14001:2015.

ISO 14001 is a standalone document that can be applied

without reference to any other documents.

While “Notes to Entry” in Clause 3 (Terms and definitions) are

normative, references to other standards in those Notes to

Entry are informative only.

For example, Notes 3 and 4 to Entry 3.2.10 (“risk”) refer to

definitions of “events”, “consequences” and “likelihood” in ISO

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Guide 73:2009. Note 4 to Entry 3.4.1 (“audit”) refers to

definitions of “audit evidence” and “audit criteria” in ISO

19011:2011.

These references to other standards are provided for

information only. There is no need to purchase additional

standards. Furthermore, anyone interested in the terms and

definitions in other ISO standards can preview elements of

these standards on the ISO Online Browsing Platform (OBP) at

no charge, including the Foreword, Introduction, Scope,

Normative references and Terms and definitions.

Access is enabled by visiting the ISO site at

https://www.iso.org/obp/ui.

3.0, 3.2.6,

6.2

Is Section 3, Terms and Definitions, binding and,

if so, may an auditor determine whether

"appropriate" environmental objectives have

been set to meet the requirements of

definitions 3.2.6?

The Introduction to Section 3, Terms and Definitions states:

“For purposes of this document, the following terms and

definitions apply.” The only sections of ISO 14001 against

which an organization’s conformance is audited are Sections

4 through 10, EMS Requirements, the terms of which are

clarified by the Definitions in Section 3. With regard to

environmental objectives, an auditor is limited to assessing

whether the organization conforms to the requirements

specified in Section 6.2. If the environmental objectives are

consistent with the environmental policy, and their

development has taken into account the organization’s

significant environmental aspects and associated

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compliance obligations and considered its risks and

opportunities then the objectives are consistent with the

standard.

3.1.5 Are there any situations in which “top

management” refers to persons outside the scope

of the environmental management system?

No.

Top management is defined in relation to the scope of the

EMS. If the EMS covers the entire organization, top

management is the person or people who direct and control

the entire organization. If the EMS covers only part of an

organization, top management is the person or people who

direct and control that part of the organization. Note 2 to Entry

in the definition of top management (3.1.5) is intended to

clarify this point, but the phrase “the scope of the

management system” in that Note to Entry might lead to some

confusion. This phrase means the scope of the environmental

management system. It should not be misunderstood as a

reference to an organization’s generic management system,

quality management system or some other discipline‐specific

management system. It is not intended to broaden the scope

of the EMS beyond what the organization has established or to

extend the scope of the internal audit beyond the scope of the

EMS.

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3.2.9 Does the term “compliance obligation” in ISO

14001:2015 have the same meaning as the phrase

“legal requirements and other requirements to

which the organization subscribes” in the previous

Yes.

Clause A.3 states: “The phrase ‘compliance obligations’

replaces the phrase ‘legal requirements and other

requirements to which the organization subscribes’ used in

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edition? prior editions of this International Standard. The intent of this

new phrase does not differ from that of the previous edition.”

3.2.10 There appears to be ambiguity in ISO 14001:2015

regarding whether the term “risk” has only a

negative connotation or includes both negative

and positive connotations. The definition of “risk”

(3.2.10) states that risk can be positive or

negative, but the definition of “risks and

opportunities”(3.2.11) implies that risk is only

negative, while opportunities are positive. May an

organization decide for itself whether to use the

term “risk” in its Environmental Management

System as a solely negative concept or as both a

negative and positive concept?

Yes.

ISO 14001:2015 requires an organization to identify and

address both the potential adverse and the potential beneficial

effects of uncertainty, but the organization may decide for

itself what terminology it will use to capture these concepts.

Each organization may decide for itself whether to use the

term “risk” to capture potential adverse effects of uncertainty

and the term “opportunities” to capture potential positive

effects of uncertainty, or to use the term “risk” to encompass

both potential negative and positive effects of uncertainty. As

Annex A.2 states, there is no requirement to apply the

terminology used in the standard to the organization’s EMS

documentation, or to replace the terms used by the

organization with the terms used in the standard. In deciding

what terms to use, organizations should be aware that

although the definitions of “risk” (3.2.10) and “risks and

opportunities” (3.2.11) take different approaches to the

concept of risk, only the term “risks and opportunities” is used

in the clauses of the standard that contain requirements.

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3.3.4 In Note 1 to Entry 3.3.4 “outsource,” does the

phrase “outside the scope of the management

system” mean “outside the scope of the

environmental management system”?

Yes.

The intent of the definition of “outsource” in ISO 14001:2015 is

to cover situations where a process or function that is within

the scope of the environmental management system is

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performed by an organization that is outside the organizational

boundaries of the environmental management system as

determined by the organization. The definition is not intended

to capture processes or functions that are outside the scope of

the environmental management system as established by the

organization.

4.1

4.2

7.5

Is an organization required to establish a process

in order to meet the requirements in 4.1 and 4.2

that it determine its context, relevant interested

parties and their needs and expectations?

Is an organization required to develop and

maintain documented lists of its external and

internal issues, its relevant interested parties and

their needs and expectations?

Clauses 4.1 and 4.2 do not state a requirement for a process

nor does it state a requirement for maintaining or retaining

documented information.

The intent behind using the word “determine” is that the

organization generates information (knowledge) regarding its

“understanding of the needs and expectations of interested

parties” and of its “external and internal issues.” A secondary

intent in changing from the use of the word “identify” in the

2004 edition of ISO 14001 to “determine” in the 2015 edition is

to conform to Annex SL management system terminology.

The term “determine” implies that the organization make

some specific effort to generate information that results in

knowledge. While a process is not required for these

determinations, whether or not to have a process is a

consideration for the organization to make when developing

its EMS (See Clause 4.4).

The decision to document the knowledge gained or the means

of acquiring it is made by the organization by considering

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Clause 7.5.1, which gives the organization flexibility as to which

processes it needs to document and records it needs to keep in

order to make the EMS effective. If the organization decides

documentation is the best way to give guidance to users and to

achieve consistency, then documentation should be

considered.

Whether documented or not, an understanding of the relevant

needs and expectations of interested parties as well as of

external and internal issues would be evident in the

implemented EMS; for example, in the determination of risks

and opportunities that need to be addressed.

4 and 6 Does ISO 14001 require an organization to

demonstrate that it has addressed requirements

related to environmental aspects, significant

environmental aspects, policy commitments,

context issues and concerns, risk and

opportunities and compliance obligations

individually for each corresponding sub-clause in

ISO 14001, or can an organization demonstrate

that it has addressed these collectively, through

the significant environmental aspects

determination process? For example, can an

organization consider its policy commitments,

context and compliance obligations to inform it’s

determination of significant aspects?

ISO 14001 does not mandate separate processes or procedures

to be used for “addressing” its requirements – provided the

requirements are, in fact, addressed. For example, an

organization might have a single “environmental planning”

process that addresses a number of requirements set out in

Clauses 4 and 6. The organization needs to provide evidence

that each of the separate requirements are addressed.

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(4 and 6)

6.1.1

6.1.2

3.2.11

3.2.2

Does ISO 14001:2015 allow an organization to

consider environmental risks and opportunities as

environmental aspects, and those aspects that it

intends to address, as its significant environment

aspects?

There is a relationship between an organization’s significant

environmental aspects and the risks and opportunities related

to its environmental aspects (see 6.1.1), but they should not be

necessarily treated as identical. The definition of “risks and

opportunities” is not the same as “significant environmental

aspects.” ISO 14001 defines risks and opportunities as

potential adverse effects (threats) and potential beneficial

effects (opportunities). A significant environmental aspect is

defined as an environmental aspect (3.2.2) that has or can

have one or more significant environmental impact(s), whether

adverse or beneficial.

Environmental aspects can result in risks and opportunities,

which can be determined as part of the significance evaluation,

or determined separately. If an aspect has been identified as a

significant environmental aspect, the organization would need

to address the identified risks and opportunities associated

with this aspect, in order to minimize or prevent its adverse

impact, or enhance its beneficial effect on the environment.

However, there may be other risks and opportunities that need

to be addressed in the environmental management system

(see 6.1.1). This can include risks or opportunities for an

organization, related to

· its compliance obligations (see 6.1.3);

· other issues and requirements referred to in 4.1 and

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4.2, e.g., risks or opportunities from environmental conditions that can affect the organization in negative or positive ways.

5.2

[secondary

references

: 4.2, 5.3,

6.1.3,

6.1.4, 6.2.,

7.2, 7.3,

7.4.3,

7.5.1, 9.1.,

9.2, 9.3,

10.2]

What is meant by the “commitment to fulfil its

compliance obligations” in Section 5.2(d) in ISO

14001?

The relationship between ISO 14001 and regulatory

compliance is addressed in a number of places in ISO 14001.

To understand what is meant by the “commitment to fulfill

its compliance obligations,” the standard has to be read as a

whole and the relationship between the relevant provisions

of the standard understood. This commitment is

demonstrated through the EMS processes and actions that

the organization establishes, implements and maintains to

meet ISO 14001 requirements, as follows:

• With an understanding of the needs and expectation of

the organization’s interested parties, including regulatory

agencies in particular (Section 4.2), establish, implement

and maintain a process to determine and have access to the

applicable legal requirements, and to determine how these

requirements apply to the organization (Section 6.1.3). Take

these requirements into account when planning its EMS

(Section 6.1.4).

• Establish documented objectives that take into account its

legal requirements associated with its significant

environmental aspects (Section 6.2.1). [Note: environmental

objectives need not address every legal requirement].

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• Plan actions to achieve environmental objectives,

including those relating to compliance with legal

requirements (Section 6.2.2).

• Those persons whose work can affect the organization’s

ability to fulfill its compliance obligations must be

competent based on training, education and/or experience

(Section 7.2).

• Ensure persons doing work under the organization’s

control are aware of the implications of not conforming with

the EMS, including not fulfilling the organization’s

compliance obligations (Section 7.3).

• Communicate EMS information externally, as required by

the organization’s compliance obligations and its own

communication process (Section 7.4.3).

• Establish, implement and maintain a process to

periodically evaluate compliance with legal requirements

(Section 9.1.2). These are the legal requirements identified

pursuant to Section 6.1.3.

• Establish, implement and maintain a program for

periodically conducting EMS audits, which necessarily

include those elements of the EMS that are compliance-

related (Section 9.2).

• React to nonconformities, evaluate the need for action

eliminate the cause(s) and implement corrective action

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Clause in ISO 14001


requirements must be corrected.

Taken together, these provisions mean that an organization

implementing ISO 14001 must systematically identify and

manage its compliance obligations in line with its

commitment to fulfill them. The organization’s EMS must

include the components listed above and be properly

supported with adequate resources and defined

responsibilities (Section 5.3), documented information

(Section 7.5.1), and evaluation of performance (Section 9).

The commitment to comply is reinforced by the

requirement that top management periodically review the

adequacy, suitability and effectiveness of the EMS (Section

9.3).

A legal noncompliance is not necessarily elevated to an EMS

nonconformity if, for example, it is identified and corrected

by the EMS processes. Compliance-related nonconformities

need to be corrected, even if those nonconformities have

not resulted in an actual noncompliance.

5.2, 4.3 Element 5.2 Environmental Policy states, ‘top

management shall establish, implement and

maintain an environmental policy that, within

the defined scope of its EMS, is...’ Does this

No. The Standard requires that an organization define and

document the scope of its EMS (Section 4.3) and that top

management establish, implement and maintain an

environmental policy (Section 5.2). However, there is no

requirement in ISO 14001 that an organization include specific

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mean that the policy statement must now

include wording from the scope statement to

link the operations of a location to the policy

statement?

wording from its EMS scope statement within its

environmental policy.

As used in Section 5.2, the phrase ‘within the defined scope of

its environmental management system’ is intended to promote

consistency between the scope statement and the

environmental policy. In particular, this phrase reinforces the

concept that the policy must be appropriate to the nature,

scale and environmental impacts associated with the full range

of activities, products and services covered by the EMS scope.

It is not necessary to include wording from the scope

statement in the policy.

5.2, 4.3,

3.1.4

In determining whether the environmental

policy is "appropriate to the purpose and

context of the organization, including the

nature, scale and environmental impacts of its

activities, products and services," is it relevant

for an auditor to determine whether the scope

of the policy covers all of the management units

within the organization being audited?

The auditor must determine whether the policy is

appropriate for all of those management units that are

within the scope of the EMS, as it has been defined by the

organization. Once the scope has been defined, all activities,

products, and services that fall within its boundaries need to

be included. The sum of those units must be consistent with

the Section 3.1.4 definition of an “organization.”

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6.1 Does the organization have to identify at least one

risk or opportunity that needs to be addressed,

i.e. at least one potential adverse effect (threat) or

beneficial effect (opportunity) that needs to be

addressed?

Although there is no explicit requirement in Clause 6.1. of ISO

14001:2015 that an organization will identify one or more risks

or opportunities that need to be addressed, there is an

underlying assumption that the organization will do so.

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Risks and opportunities are defined as potential adverse

effects (threats) or beneficial effects (opportunities), which

may result from environmental aspects, compliance

obligations, or from other issues and requirements identified

as part of the context of the organization. The intent is for the

organization to determine which risks or opportunities it

considers to be important to address within its EMS, in order

to achieve the intended outcomes of its EMS and support

continual improvement.

6.1.2 Does ISO 14001:2015 require Life Cycle

Assessments (LCAs) to be completed as part of the

enhanced life cycle perspective requirements?

ISO 14044:2006 Clause 3.2.1, defines a life cycle assessment as

“a compilation and evaluation of the inputs, outputs and the

potential environmental impacts of a product system

throughout its life cycle”.

ISO 14001:2015 requires taking a life cycle perspective. In

Annex A6.1.2, a life cycle perspective is explained as follows:

“This does not require a detailed life cycle assessment; thinking

carefully about the life cycle stages that can be controlled or

influenced by the organization is sufficient”. The life cycle

stages of a product (or service) include acquisition of raw

materials, design, production, transportation/delivery, use,

end-of life treatment and final disposal (3.3.3). In Clause 6.1.2,

ISO 14001:2015 requires the organization to consider these life

cycle stages when determining the environmental aspects that

it can control or can influence.

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6.1.2 Must a regulated environmental aspect

automatically be considered a significant

environmental aspect?

No. Section 6.1.2 requires an organization to “determine

those aspects that have or can have a significant

environmental impact, i.e., significant environmental

aspects, by using established criteria.” ISO 14001 does not

establish the criteria for determining significance. Section

A.6.2 states that environmental criteria are the primary and

minimum criteria for assessing environmental aspects, but it

is the organization that sets the criteria for determining

those that are significant.

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6.1.2 Does ISO 14001:2015 require the organization to

apply a life cycle perspective when determining

which of its environmental aspects are significant,

i.e., in its criteria for determining significance?

In Clause 6.1.2 of ISO 14001:2015, an organization needs to

consider a life cycle perspective when identifying the

environmental aspects that it can control or influence.

There is no single method for determining significant

environmental aspects. As stated in A.6.1.2, environmental

criteria are the primary and minimum criteria for assessing

environmental aspects to determine significance. The

organization has the autonomy to apply additional criteria,

including criteria related to life cycle perspective.

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6.1.2

Is it permissible for a small organization to

declare that they have no significant aspects

and still be conformant to the ISO 14001

standard?

Although there is no explicit requirement in ISO 14001 that

an organization will identify one or more significant

environmental aspects, there is an underlying assumption

that the organization will do so. The intent of the

requirement to determine those aspects that an

organization considers significant is to enable the

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organization to focus attention and resources on its most

important environmental aspects, recognizing that not all

aspects require or deserve the same degree of

management. ISO 14001 does not define “significance” nor

does it identify any external or absolute standard for what

will be considered significant. Significance is intended to be

a relative term. What is significant for one organization may

not be for another, and what an organization considers a

significant aspect may change over time. The use of

‘significance’ in ISO 14001 was intended to be an aid in

managing a range of environmental aspects.

There is no special category of requirements in ISO 14001

for “small” organizations. The requirements for an ISO

14001 EMS, including those regarding significant aspects,

are intended to apply to “…all types and sizes of

organizations…”

Note: Regarding whether an organization has to identify at

least one risk or opportunity that needs to be addressed,

i.e., at least one potential adverse effect (threat) or

beneficial effect (opportunity), see COI 16-08.A2.

6.1.3 Does Section 6.1.3 “Compliance obligations”

require that the “facility” (the relevant

organization) must have its own direct

knowledge of the environmental legal

This question refers specifically to Section 6.1.3 which

requires that “The organization shall determine and have

access to compliance obligations related to its

environmental aspects”.

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requirements that are applicable to its products

in all countries into which they may be exported

and not be able to rely on either a related

corporate entity which sells the product in a

foreign country or an independent importer

customer to which it ships the product to have

and apply such information?

With regard to products, the Standard does not specify

geographic boundaries, nor how the determination and

access requirements can be accomplished by the

organization. Section 6.1.1 requires the organization to

establish, implement and maintain a process to meet the

requirements in 6.1.2 – 6.1.4. Therefore, it is up to the

organization to establish a process as to how it will

determine and have access to such legal requirements. This

may depend largely on the scope of the EMS and the level

of control or influence an organization can exercise over its

products as stated in Section 6.1.2. If the organization

defines its process as depending on outside organizations to

assist it in meeting that requirement, then that is the choice

of the organization. The Standard provides flexibility to the

organization to define how such legal requirements will be

determined and who will do it.

6.1.3 Must an organization have access to the ISO

14001 standard either in hard copy, via

computer or by an external source since the

organization is certified to that standard?

An organization seeking to conform to ISO 14001 must have

access to information related to the ISO 14001

requirements, including any subsequent revision, so that it

can take these requirements into account in establishing,

implementing and maintaining its environmental

management system.

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Several sources of this information are available to an

organization including, but not limited to, an electronic or

hard copy of the ISO 14001 standard itself.

6.1.3,

3.2.1

Can an organization address only applicable EPA

legal requirements when identifying its legal

requirements affecting the EMS and exclude

any applicable OSHA requirement when the

definition of environment in ISO 14001 states

"surroundings in which an organization

operates, including air, water, land, natural

resources, flora, fauna, humans and their

interrelationships”?

Clause 6.1.3, “Compliance obligations” requires an

organization to determine the legal requirements and other

requirements that it has to, or chooses to, comply with

related to its environmental aspects. Regulations issued by

an “environmental” agency are not necessarily the only

legal requirements applicable to environmental aspects. It is

not a matter of which agency issues a legal requirement, but

rather whether that requirement applies to an identified

environmental aspect within the scope of the EMS. While

“humans” are included in the definition of environment, not

all legal requirements that apply to “humans” are

necessarily applicable to its environmental aspects, or part

of its EMS.

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6.1.3,

7.5.3,

3.2.9

Is ISO 14001Standard a “compliance obligation”

under Clause 6.1.3 and also a document of

external origin?

Yes, ISO 14001 is a “compliance obligation”. ISO 14001

defines compliance obligations (see 3.2.9) to include

requirements that an organization has to or chooses to

comply with, and notes that these can arise from mandatory

requirements as well as voluntary commitments, such as

organizational and industry standards, and codes of

practice.

ISO 14001 is documented information of external origin. The

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organization cannot update it on its own. The Technical

Committee, through ISO, issues revisions.

6.1.3,

6.1.2,

7.5.1

Does clause 6.1.3(a) mean that an organization

must demonstrate a linkage, if any, between

each aspect and its applicable legal and other

requirements (i.e., its compliance obligations)?

If so, what documentation is required?

Clause 6.1.3(a) of ISO14001 requires an organization to

determine and have access to the legal requirements that the

organization has to or chooses to comply with (i.e., compliance

obligations) related to its environmental aspects. An

organization must identify and have access to the

requirements that pertain to its environmental aspects, and

must also know how these requirements apply to the

organization. The intent is that the organization understands

these requirements sufficiently to address them in the EMS.

ISO 14001 does not require establishing a “linkage” between

each environmental aspect and the identified compliance

obligations.

Regarding documentation, ISO 14001 Clause 6.1.3 requires the

organization to maintain documented information of its

compliance obligations. However, there is no specific

requirement in ISO 14001 for documenting the determination

of how compliance obligations apply. Clause 7.5.1(b)

Documented Information - General leaves it up to each

organization to determine the documented information that is

necessary to ensure the effectiveness of the EMS.

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6.1.3 Does Section 6.1.3 “Compliance obligations”

require that the “facility” (the relevant

This question refers specifically to Section 6.1.3 which

requires that “The organization shall determine and have

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organization) must have its own direct

knowledge of the environmental legal

requirements that are applicable to its products

in all countries into which they may be exported

and not be able to rely on either a related

corporate entity which sells the product in a

foreign country or an independent importer

customer to which it ships the product to have

and apply such information?

access to compliance obligations related to its

environmental aspects”.

With regard to products, the Standard does not specify

geographic boundaries, nor how the determination and

access requirements can be accomplished by the

organization. Section 6.1.1 requires the organization to

establish, implement and maintain a process to meet the

requirements in 6.1.2 – 6.1.4. Therefore, it is up to the

organization to establish a process as to how it will

determine and have access to such legal requirements. This

may depend largely on the scope of the EMS and the level

of control or influence an organization can exercise over its

products as stated in Section 6.1.2. If the organization

defines its process as depending on outside organizations to

assist it in meeting that requirement, then that is the choice

of the organization. The Standard provides flexibility to the

organization to define how such legal requirements will be

determined and who will do it.

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6.1.3,

7.5.3

Are the compliance obligations identified under

Clause 6.1.3 also documented information of

external origin under clause 7.5.3?

Yes, as long as the source of the documented information

that contains the compliance obligations is generated,

documented and controlled by an entity external to the

organization.

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6.1.4 In Clause 6.1.4 A(3), which “risks and

opportunities” is an organization required to plan

actions to address?

An organization is not required to plan actions to address every

risk and opportunity, only those it has determined need to be

addressed. This determination is an output of Clause 6.1.1. An

organization retains the authority and accountability to decide

how it fulfils the requirements of ISO 14001, including

determining which risks and opportunities need to be

addressed.

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6.2 Is it a non-conformance if an organization

establishes environmental objectives but, at the

time of the audit, none relate to an identified

significant aspect?

No. Clause 6.2.1 requires that significant environmental

aspects and compliance obligations be taken into account

when establishing and reviewing environmental objectives.

It also requires that risks and opportunities be considered.

However, it does not explicitly require that there be an

objective related to significant aspects, compliance

obligations or risks and opportunities at all times. It is the

intent of the standard that the organization be able to

demonstrate that it has taken significant aspects and

compliance obligations into account, and that it considers

risks and opportunities in setting objectives. Over time,

however, given the required commitment to continual

improvement, it would be expected that there would be

one or more objectives related to one or more significant

aspects, compliance obligations and risks and opportunities

to demonstrate conformance to ISO 14001.

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6.2.1, Must objectives be set which are explicitly This question refers specifically to the setting of ANSI - 2019






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6.1.2,

6.1.3, 5.2

related to the organization's commitment to

environmental protection, including pollution

prevention or are the scope and content of

environmental objectives solely at the

discretion of the organization?

environmental objectives, which is covered by Section 6.2 of

the standard.

This question raises the issue that one cannot read a particular

sentence or section of the ISO 14001 standard in isolation from

the other sections of the standard. There is an

interrelationship between the requirements in some sections

with the requirements in other sections. This question deals

with one of those interrelationships.

Section 6.2 does not by itself require that the documented

objectives explicitly mention environmental protection or

prevention of pollution. However, Section 6.2 does require the

organization to take into account its significant environmental

aspects and associated compliance obligations when setting its

objectives. It also clearly states that the objectives “shall be

consistent” with the organization’s environmental policy.

According to section 5.2 the environmental policy, which is set

by top management and must be implemented and be made

available to the public, must include commitments to the

protection of the environment including prevention of

pollution. Therefore, while organizations have the discretion to

set their own objectives, they must do so within these

parameters.

In addition, setting environmental objectives is not the only

way that an organization can support its commitment to

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environmental protection, including prevention of pollution.

An organization can take action within the EMS related to

competence, awareness, and communication (see clause 7,

Support); operational planning and control, or emergency

preparedness and response (see clause 8, Operation); or

monitoring, measurement, analysis, and evaluation (see clause

9, Performance Evaluation). Note: The above Q&A originally

related to both compliance with regulatory requirements as

well as prevention of pollution. The discussion on compliance

with regulatory requirements has been moved to the

subsequent Q&A 99-03.A1.

7.2 Does ISO 14001 imply some consideration by

the organization of legal requirements for

training of employees in establishing

competence and training?

ISO 14001 in Section 7.2 requires the determination of

training needs associated with an organization’s

environmental aspects and its environmental management

system. If an organization is legally required to provide

certain kinds of training, such training should be identified

as a "need."

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7.5.1 If a small business such as a fast food franchise,

automotive dealership, flower shop, funeral

home, grocery store, pizza shop, etc. - were to

adopt ISO 14001, what level of documentation

should they provide to demonstrate conformity to

ISO 14001?

ISO 14001 clause 7.5.1 requires an organization to include

documented information required by the Standard, and any

other documented information determined by the

organization as necessary for effectiveness of its EMS. The

specific documentation required by the Standard is described

within the applicable clauses of the Standard. For example,

information about environmental aspects that must be

documented is found in clause 6.1.2.

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The Standard recognizes that the extent of documented

information can differ from one organization to another due to

a number of reasons, including the size of the organization.

For that reason, in some clauses of the Standard it provides

flexibility for an organization to determine the extent of

documented information required. In these specific cases, it is

incumbent upon the organization to determine the level of

documentation required to ensure its EMS is implemented as

planned and determine the records necessary to provide

objective evidence of conformance to ISO 14001 requirements.

Regardless of size, an organization may determine it needs

additional documents and records, over and above what is

required by the Standard to ensure its EMS is effective.

For ease in reference, the following lists provide the minimum

documented information, either documents or records, that is

required by ISO 14001 and the applicable clause that specifies

the requirement. Where the Standard offers flexibility to the

organization, the applicable text is noted in italics.

An organization shall maintain documentation of:

— the scope of its EMS (see 4.3);

— its environmental policy (see 5.2);

— the process(es) needed to meet requirements of clause

6.1.1 through 6.1.4, to the extent necessary to have



Clause in ISO 14001


confidence they are carried out as planned (see 6.1.1);

— the risks and opportunities that it determines need to be

addressed (see 6.1.1);

— environmental aspects and associated environmental

impacts, criteria used to determine significant

environmental aspects, and its significant environmental

aspects (see 6.1.2);

— its compliance obligations (see 6.1.3);

— its environmental objectives (see 6.2.1);

— the operational control processes needed to meet EMS

requirements and to implement the actions identified in

clause 6.1 and 6.2, to the extent necessary to have

confidence the processes have been carried out as planned

(see 8.1);

— the process(es) needed to prepare for and respond to potential emergency situations, to the extent necessary to have confidence the process(es) is (are) carried out as planned (see 8.2).

An organization shall retain records as evidence of:

— competence, as appropriate (see 7.2);

— communications, as appropriate (see 7.4.1);

— monitoring, measurement, analysis and evaluation results,

as appropriate (see 9.1.1);

— compliance evaluation result(s) (see 9.1.2);

— implementation of the audit program, and the audit results



Clause in ISO 14001


(see 9.2);

— the results of management reviews (see 9.3);

— the nature of identified nonconformities and any

subsequent actions taken, and the results of any corrective

action (see 10.2).

7.5.3 If a facility such as a bag house collecting

hazardous materials is operated using the

manufacturer's operations manual in lieu of the

organization preparing its own internal manual

or procedures, is the manufacturer's operations

manual a document of external origin under

clause 7.5.3?

Yes, unless the organization modifies that manual and

makes it its own, in which case it becomes an internal

document. As long as the organization is committed to using

the manufacturer's manual including any subsequent

updated version, then the manual is of external origin.

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7.5.3 If a document of external origin is referenced in

a document determined necessary by an

organization for EMS planning or operational

purposes, in what ways must such documents

be identified and controlled?

This question refers specifically to the last paragraph of Section

7.5.3 which requires the organization to ensure “Documented

information of external origin determined by the organization

to be necessary for the planning and operation of the

environmental management system shall be identified, as

appropriate, and controlled”.

The standard does not specify (a) particular way(s) to identify

documented information of external origin that is necessary or

to control this information. It is up to the organization to

define the process (or processes) it will use. The intent of the

standard is that the organization considers and decides if any

external documented information is necessary for the planning

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and operation of its EMS. If such documented information is

identified by the organization, the process(es) established

must ensure that the documented information that is

necessary to the EMS is the correct information and is

available to those who need it. It is not the intention to require

identification and control of external documented information

used only for reference purposes.

The process(es) for identifying and controlling external

documented information does not have to be the same

process(es) used for internal documented information. The

standard requires only the identification and control of

distribution of documented information of external origin and

does not require the same degree of control for such

documented information as it does for internal documented

information that are part of the EMS.

8.1 , 3.3.4 ISO 14001 Clause 8.1 requires an organization to

ensure that outsourced processes are controlled

or influenced. The text in Annex section A.8.1

states that an outsourced process is one that

fulfils a list of criteria, including “liability for

conforming to requirements is retained by the

organization;” which may allow exclusion of some

procured services that meet the definition of

outsourced processes in 3.3.4 from the “control or

ISO standards don't establish legal liability - they are voluntary

and do not change legal obligations. This criterion in A.8.1

relates to the arrangement between the parties (see definition

3.3.4) and whether or not the organization retains liability (i.e.,

responsibility) for conforming to requirements. These

requirements may include but are not limited to legal

requirements.

Outsourced processes are a subset of procured services that

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influence” requirement in 8.1. How is the phrase

“liability for conforming to requirements” to be

understood? Does this mean strict legal liability

for compliance with environmental regulations, or

something more?

meet the criteria of A.8.1. These criteria assist an organization

in determining which of its procured services are outsourced

processes. The organization defines in its EMS the type and

extent of control or influence to be applied to the outsourced

process.

8.1 What is an outsourced process? Is every process

or service obtained from an external provider an

outsourced process?

ISO 14001:2015 defines “outsource” as “make an arrangement

where an external organization performs part of an

organization’s function or process” (see Clause 3.3.4). A

process or service obtained from an external provider is not

necessarily an outsourced process. Outsourced processes can

be viewed as a subset of these externally provided processes

or services.

Criteria that an organization can use to distinguish outsourced

processes from other processes and services are described in

Annex A.8.1, which states that an outsourced process is one

that fulfils all of the following:

– it is within the scope of the environmental management system;

– it is integral to the organization’s functioning; – it is needed for the environmental management

system to achieve its intended outcome; – liability for conforming to requirements is retained by

the organization; – the organization and the external provider have a

relationship where the process is perceived by interested parties as being carried out by the

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organization.

8.1 If an organization does not have any outsourced

processes, to what extent does clause 8.1 apply?

Do the requirements in the paragraph starting

“consistent with a life cycle perspective” only

apply to outsourced processes?

If an organization has no outsourced processes, the only

requirements of Clause 8.1 that are not applicable to its EMS

are:

– The org shall ensure that outsourced processes are

controlled or influenced.

– The type and extent of control or influence to be

applied to the processes shall be defined within the

environmental management system.

All of the other requirements in 8.1 are independent of

whether a process is outsourced or not, including the

requirements in the paragraph starting with ‘Consistent with a

life cycle perspective…’

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8.1 Does the phrase, “consistent with a life cycle

perspective’ in Clause 8.1, Operational Planning

and Control mean than an organization needs to

consider a life cycle perspective a second time,

with regard to operational planning and control?

There is no requirement in Clause 8.1 that the organization

undergo an activity to reconsider a life cycle perspective. There

is also no requirement for a formal life cycle assessment (see

COI 16-01.A1). The four bullets in Clause 8.1 paragraph 4, a) to

d) specify requirements that are typically associated with

specific life cycle stages.

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8.1 The operational control clause of ISO 14001:2004

(Clause 4.4.6) referred to identifying and planning

those operations associated with significant

environmental aspects. The operational planning

As was the case in ISO 14001:2004 Clause 4.4.6, Clause 8.1 in

the revised standard remains focused on planning and

controlling the operations of an organization. The organization

decides the controls needed for operational processes

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and control clause of ISO 14001:2015 (Clause 8.1)

refers to processes needed to meet

environmental management system

requirements. Does the revised standard still refer

to control of the organization’s operational

processes?

associated with its significant environmental aspects,

compliance obligations, risks and opportunities that need to be

addressed, and environmental objectives. These operational

processes are controlled by establishing operating criteria and

implementing methods to meet the criteria.

Institute

8.1, 7.2,

7.3, 7.4,

8.2

Company A out-sources part of their production

operations (e.g., parts metal coating or painting)

to Company B. Company B is a separate

company located in a different

city/state/country. Is Company B considered

“persons doing work under” Company A’s

control? If so, what does ISO 14001 require

Company A to do regarding ensuring the

competence of Company B? What does ISO

14001 require Company A to do regarding

identifying training needs for Company B

employees?

This question arises from the phrase “persons doing work

under its control.” This phrase, appears in four places in the

normative clauses of ISO 14001:

1. the organization must determine the necessary competence

of persons doing work under its control that affects its

environmental performance and its ability to fulfil its

compliance obligations, and ensure that these persons are

competent on the basis of appropriate education, training or

experience, (Section 7.2, a-b) , and

2. persons doing work under the organization’s control must

be made aware of certain key provisions of its EMS (Section

7.3, a-d).

3. the organization must ensure its communication process(es)

enable(s) persons doing work under the organization’s control

to contribute to continual improvement (Section 7.4.2, b).

4. the organization must provide relevant information and

training related to emergency preparedness and response, as

appropriate, to relevant interested parties, including persons

working under its control (Section 8.2, f).

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The phrase “doing work under the organization’s control” is

not defined in ISO 14001. The organization implementing the

EMS determines who those persons are, based on the

activities, products, and services within the scope of the EMS

established by the organization. The overall intent of the

phrase is to ensure the organization looks beyond its direct

employees and considers other persons performing tasks

within that scope when addressing competence and awareness

requirements. The use of this phrase is not intended to change

any legal relationship between the organization and any

individual.

The phrase clearly covers an organization’s own employees,

including contract and temporary employees. It also could

apply to individual contractors, or individuals employed by

contractors working for the organization or other suppliers of

goods or services if those individuals are engaged in tasks

within the scope of the organization’s EMS. Persons covered by

this phrase will be determined by the organization on a case-

by-case basis.

The requirements for ensuring competence, awareness, its

internal communication process, and information or training

on emergency preparedness and response in key EMS

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Clause in ISO 14001


behalf of the organization within its EMS scope. The

requirements related to competency, however, apply only to a

subset of such persons: those performing tasks which can

affect its environmental performance and its ability to fulfil its

compliance obligations. For these persons, Section 7.2 requires

that the organization ensure that they are competent (based

on education, training or experience).

Section 7.2 also requires an organization to identify training

needs associated with its environmental aspects and its EMS.

Although it does not explicitly require identifying training

needs of persons who work “on its behalf”, such persons

would be included if the tasks they perform are identified as

requiring training. This section does not require the

organization to provide training to such persons, but it does

require that needs for training be identified and met. ISO

14001 does not specify the method or processes that an

organization must use to satisfy any of the requirements of

Section 7.2.

In the example given in the question, Company A would need

to determine whether there are any tasks being performed by

persons within Company B that are related to Company A’s

environmental aspects of activities, products or services within

its EMS scope. If so, Company A would need to implement

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Clause in ISO 14001


requirements related to these particular tasks (see Section 7.3

a-d). Company A also would need to determine if there are any

tasks that can affect its environmental performance or ability

to fulfill its compliance obligation, or, are related to emergency

preparedness and response being performed by persons within

Company B. If so, Company A would be required to establish

some means of ensuring that those persons are competent to

perform those tasks. ISO 14001 does not specify how this

should be done. Company A has the discretion to establish a

process that best suits its needs.

If the identification of persons doing work under the

organization’s control raises questions of potential legal

liability, those should be addressed by the organization’s legal

counsel.

8.2 8.2 e) requires the organization to review “and”

revise the process(es) and planned response

actions. Here, the word “shall” apply to both verbs

(organization SHALL review… / organization SHALL

revise…). Is an organization ALWAYS required to

“revise” the process(es) ?

If the periodical review shows that the process(es) and planned

response actions has(have) no trouble/problem AT ALL, then

the revision may not be necessary. However, please also keep

in mind that such situation is unlikely to happen, because this

clause is defining a particular case like “the occurrence of

emergency situations or tests”.

Therefore, if we want to be exact to the grammatical meaning

keeping in mind that there “may” be a case where no revision

would be needed at all (which seldom happens), the word

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“where necessary” could be added in the sentence as follows:

e) periodically review, and where necessary, revise the

process(es) and planned response actions, in particular after

the occurrence of emergency situations or tests;

9.1.2 Is the intent of the requirement in clause 9.1.2,

"Evaluation of Compliance" that only those

working for on or behalf of the organization

conduct the evaluation(s) of compliance, or can

these evaluations include those conducted by

regulatory authorities?

The intent of Clause 9.1.2 is that an organization will

determine how it will periodically evaluate compliance, and

can choose to include evaluations conducted by internal

staff, consultants, and/or regulatory agencies. An

organization can use information from regulatory agency

audits/inspections as part of its compliance evaluation

process, but cannot rely on such audits/inspections alone.

Periodic compliance assessments performed on a sampling

basis (for example, those conducted internally, by

consultants, and/or by regulatory agencies) may satisfy the

requirement of clause 9.1.2 if, taken together, they cover all

applicable legal requirements over a period defined by the

organization.

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9.1.2 Is there an expectation in ISO 14001 that

compliance with ALL applicable compliance

obligations will be assessed for ALL

environmental media over some time frame

(e.g., every 3-5 years), or are periodic

ISO 14001 requires the organization to evaluate the

fulfilment of its compliance obligations (Clause 9.1.2). It

does not specify a particular methodology or frequency for

doing so. Periodic compliance assessments performed on a

sampling basis may satisfy this requirement if, taken

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compliance assessments on a sampling basis

(selected based on the environmental

importance of activities, history of

noncompliance, and other factors) considered

adequate?

together, they cover all applicable compliance obligations

over a period defined by the organization.

9.2, 7.2 Does the standard require companies to select

internal auditors who are Certified

Environmental Engineers, have a background in

Environmental Management Programs, or have

previous work experience in the environmental

field? Based on section 9.2 of ISO 14001, "Select

auditors and conduct audits to ensure

objectivity and the impartiality of the audit

process." I believe that I can use personnel who

are trained in conducting audits regardless of

their Environmental work experience. I believe

that in order to ensure objectivity and

impartiality, the internal auditor should be

independent of the Environmental group. I also

believe that with proper training/education,

that the QMS internal audit team can audit the

EMS program. Can you provide some

clarification on this point?

ISO14001 does not contain specific requirements on

certification, education, or work experience for internal

auditors or any other position. Clause 7.2 on Competence,

requires an organization to “determine the necessary

competence of persons doing work under its control that

affects its environmental performance…”; “ensure that

these persons are competent on the basis of appropriate

education, training or experience”, “where applicable, take

actions to acquire the necessary competence, and evaluate

the effectiveness of the actions taken”; and, “retain

appropriate documentation as evidence of competence”.

These actions can include the provision of training,

mentoring, reassignment and hiring or contracting

competent persons. Thus, it is the intent of ISO 14001 that

the organization decides what education, training or

experience, including certifications, is appropriate for its

internal auditors.

Note: Although not required by ISO 14001, guidance on

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selection and competence of internal auditors can be found

in ISO 19011.

9.2 If work is performed on multiple shifts that 8.1

Operational planning and control is required, or

8.2 Emergency preparedness and response may

be necessary, does 9.2 Internal audit require

that all shifts be included in the organization’s

internal audits?

ISO 14001 contains no specific requirement to conduct an

internal audit of all shifts. The organization must decide on

the appropriate scope of its internal audits to meet the

requirements of clause 9.2.2 and its own needs for audit

information. For additional clarification, refer to COI 02-

03.A2 on the topic of internal auditing.

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9.2 Does the requirement for internal audit (9.2)

include a compliance or financial audit?

No.

The internal audit provides information about whether the

EMS conforms to the requirements of the Standard and the

organization’s own requirements for its EMS (9.2.1). The

organization determines which requirements beyond those of

the Standard itself are EMS requirements, and will thus be

included in the scope of the internal audit. The internal audit is

not a financial audit, a compliance audit, or an audit of

conformity with interested parties’ needs and expectations.

The Standard’s new definition of nonconformity (3.4.3) clarifies

this by stating in Note 1 to Entry that nonconformity does not

mean non‐fulfilment of any and all requirements, it only means

non‐fulfilment of the requirements of the Standard and

additional EMS requirements the organization establishes for

itself. There is no change from the previous edition of the

Standard in this respect.

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9.2.2 Does ISO 14001 section 9.2 require that the

organization conduct its internal EMS audit on

an annual basis?

No. Section 9.2.2 requires an organization to establish the

frequency of its environmental management system audits.

Since the "frequency” is not defined by ISO 14001, these

audits may or may not be conducted on an annual basis.

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9.2.2 Does ISO 14001 section 9.2 require that the

organization conduct its internal EMS audit on

an annual basis covering all elements (i.e. full

scope) of the ISO 14001 standard?

This question is in two parts. The first part asks whether ISO

14001 requires an annual audit. See the response to 02-

03.A1 for the answer to that question.

The second part asks whether an internal EMS audit must

cover all elements of ISO 14001 during the audit. The

environmental management system audit program takes

into consideration the environmental importance of the

process concerned, changes affecting the organization, and

the results of previous audits. According to ISO 14001, in

order to be comprehensive, the audit program shall cover

the audit criteria, scope, frequency and methods, as well as

the responsibilities and requirements for planning and

conducting audits, reporting results, and retaining

associated documented information. ISO 14001 does not

require that all elements of ISO 14001 be audited each and

every time an audit is conducted, nor does it require that

every single element be audited within a one-year period

but rather that the program shall be established with

consideration of the various factors described above.

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In addition, in determining its environmental management

system audit program, the organization should consider the

purpose of the audit, i.e., to determine whether or not the

environmental management system conforms to 1) the

organization’s own requirements for its environmental

management system; 2) the requirements of this

International Standard, and whether or not the

environmental management system has been effectively

implemented and maintained. These factors should be

considered by the organization in determining the necessity

for auditing each element of ISO 14001 and at what

frequency, e.g., (a) annually, or (b) each and every time an

audit is conducted, or (c) over a period that exceeds one

year.

Note: the questions and their responses above are provided in response to questions related to ISO 14001:2015. One should not infer that these responses are

valid with regard to the 2004 version of ISO 14001.


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